AirVenture 2010: Avgas — Top 'Er Off with 100 Gallons of Muddled Message

In a moment of absolute delusional optimism, when I left for Oshkosh last week, I secretly thought that AirVenture would, at long last, produce the briefest, shining glimpses of clarity about a replacement for 100LL. My wild fantasy was that a path out of the mire would at least become visible, if not negotiable.

Sadly, just the opposite has happened thus far, leaving me to wonder if anyone in our government is even remotely capable of getting anything never mind everything into the same sock. When I got back to our press trailer Tuesday evening after an industry fuels briefing, waiting in my inbox was a press release from AOPA quoting EPA as saying essentially that it hasn't set a timeline for eliminating 100LL and, anyway, it doesn't have the authority to do that.

Huh? In other words, is the EPA saying, hey, just kiddin'…we can't do anything about that nasty old lead in your fuel? Here's the exact quote from Margo Tsirigotis Oge, director of EPA's Office of Transportation and Air Quality: "EPA has not established or proposed any date by which lead emissions from aircraft operating on leaded avgas would need to be reduced. In fact EPA does not have authority to control aviation fuels." You can judge for yourself what this statement means. Don't get your pants snagged on parsing "control aviation fuels." EPA has full statutory control over the components that go into avgas, not the gas itself. I'll let you apply your own metric about how disingenuous that statement really is.

So along comes FAA Administrator Randy Babbitt on Wednesday with this quote: "…We've had some pretty good discussions with the EPA. They've been cooperative and helpful. The EPA of course has the ability and they have the statutory authority, in fact, to say there will be no more lead in fuel..." Just in case you think we're making this up, here's the link to the video. I think Babbitt's statement is clear, unambiguous and correct. I don't think the question that prompted the quote was a blindside. I do think his support staff failed him in not informing him about what EPA said on Tuesday because I'm sure he would like to have known that what he was saying was in direct conflict with what EPA said the day before. We asked the FAA's PR team with a follow-up with Babbitt and they said they'd take it under advisement. But I'm not sure he could make his view any clearer than he did. Unless he says the flight safety card trumps all and that the EPA can be made to agree that continuing use of lead--like forever--is a worthy tradeoff between environmental threat and air safety. I don't hear anyone saying that. Yet.

To describe this as a muddled message is to give a bad name to the very word muddled. But the larger consideration is even worse. AOPA's headline on the press release said this: "EPA Tells GA Avgas Coalition That the Agency Is Committed to Working with Industry, Sets No Deadline for Unleaded Avgas." This notion was also advanced at the fuel briefing on Tuesday and it is exactly the wrong message to be sending now.

I know why it is being sent. It's a tamp down—an attempt to keep owners from panicking about fuel availability. But the way the message is likely to be interpreted is…don't worry, be happy. We've got another 20-year waiver. We've got plenty of time to solve this problem. AOPA shouldn't be behind this message, although it's right to try to seek just the right tone between complacency and panic. I recognize that this is not easy, but having the EPA essentially imply that well, there really is no deadline is just setting up the industry for a bigger fall two or three years from now. We've got to stop doing this and step up meeting this challenge.

As the Clean 100-Octane Coalition's Jon Sisk told me Wednesday, if we're going to attract innovators and entrepreneurs to risk capital to build the new fuels, we can't do that by (a) having government agencies express diametrically opposed policy statements and (b) having our own industry groups sign on to this in order to minimize the problem for the short term. If you want a bigger mess, just keep putting this off.

Can't we do any better than this? My view is that we as users, owners and operators ought to challenge the FAA and EPA to give clearer, more consistent policy statements. I didn't see that this week.

Comments (18)

Paul:
I completely agree. WE need a clear directive form the "rule makers" or nothing moves in the right direction. To throw out a "bomb" and say we will ban lead; and then have no clear path to direct a replacement, is irresponsible and places the entire industry in peril. Some pilots are foregoing new plane purchases not knowing if their engine will be obsolete in the next 5 years.
This is the wrong time in the wrong economy to be interjecting new uncertainty into GA. Things are bad enough already.

Paul - I deal with lawyers all day long, they are highly trained in the use of the English language to write a sentence that does not answer a question yet is entirely truthful: EPA - "In fact EPA does not have authority to control AVIATION FUELS" (translation - we can't control the fuel that comes out of the hose at the airport, that does not mean we can't ban one of the chemicals in the fuel. If we do ban a chemical, it's someone else's problem - but again, we can't control the stuff that comes out of the hose). FAA - "The EPA of course has the ability and they have the statutory authority, in fact, to say there will be no more lead in fuel" (no translation needed here, the statement is in complete agreement with the EPA statement above).

Be glad there is an ongoing discussion between the FAA and the EPA in these matters. Without these discussions 100 LL would have been banned long time ago.
My understanding is that through action from the AOPA (US) in the 1980:es AOPA got the FAA to demand and got acceptance from the EPA that no fuel components/formulas may be banned/changed by the EPA without the consent of the FAA because the EPA does not have the competence to evaluate the consequences. Further aviation fuels are NOT a responsibility only on a national US level. Aviation fuels are international responsibilities - because aviation by nature does not see any national borders.
So AVGAS 100 LL or not is NOT an issue only for the US but for the whole world.

However the EPA is responsible for the air quality in the US and may impose restrictions - such as a maximum amount of lead in highly populated areas. Such restriction may include less use of leaded fuels, leading to a possible dual fuel solution in order to take down the overall lead concentrations in the air.
I am not the specialist in how the US agencies are working and their responsibilities and will appreciate corrections if I am wrong.

Paul wrote "Unless he (the FAA) says the flight safety card trumps all and that the EPA can be made to agree that continuing use of lead--like forever--is a worthy tradeoff between environmental threat and air safety. I don't hear anyone saying that. Yet."

Based on some research I believe that the FAA does have the authority to override EPA regarding removal of TEL (lead) from avgas IF in the FAA's view doing so poses a material safety risk. Having tens of thousands of airplanes (many carrying cargo and/or passengers) unable to meet their certificated performance/endurance requirements due to forced use of lower octane (or equivalent) fuels certainly does pose serious system-wide safety problems.

I fully support vigorous efforts to develop alternative fuels that meet/exceed the capabilities of 100LL. But we should not abandon/forfeit the fallback option of pushing/lobbying FAA to stop Armageddon IF a cost effective alternative takes longer to develop than EPA would like.

Don't be surprised or dismayed by inconsistent messages from the FAA and EPA. They will work it out.

In my 50 years in the computing industry, I've seen many cases of sales, marketing and support saying completely inconsistent things to customers. It seems inherent in large, complex organizations. Don't think it's unique to government.

It appears that the FAA or EPA is not going give us an answer that will let us all know what to expect, and I think the reason for this is because they also have not approved any kind of fuel alternative, as some could prove to be disastrous, so instead, they just keep beating around the bush, and we are all supposed to interpret this as to what they are really saying, --- and so that is my interpretation.

But what if, -- without any comment, --- they dispense with their pounds of paperwork, and certify the current crop of Diesel engines that manufacturers already have developed that are in fact ready to go into production, i.e.; (Delta Hawk, SMA, etc.), that are currently lacking only the pounds of FAA paperwork being filled out, --- and at that point then they can comfortably tell us when 100LL is going to cease, and give us all a 5 to 10 year retrofit period.

As I understand it, the only supplier of Tetra Ethyl Lead in the world is located in France, --- and without an immediate up and running fuel alternative supplier, --- the world of GA users of 100LL would be out of fuel in about 2 weeks if that plant were to cease production today, --- but not so with Jet A and Diesel which is openly available world wide.

I think the choice is pretty clear, and that Mr. Babbit should be required to look at the facts outlined above, and make a decision during this 2010 EAA.

I dunno, the certification process is not all bad, and with the disaster over the Thielert engine I think it's okay for the certification process to be slow. I'm all for a long phase-in of unleaded avgas. The problem is, we HAVE to have progress. I'm afraid we'll see the lead issue pushed back another 20 years and an accident or bankruptcy, or buyout, or whatever at Innospec will be the end of 100LL - without warning or public comment.

If you read the full letter I don't think it's disingenuous. Even the next sentence after what you quote pretty much clarifies it, to me.

"While EPA is responsible to make the decisions with respect to what chemical or physical properties of an aircraft fuel or additive endangers the public health, the Federal Aviation Administration regulates the fuels used in aircraft engines"

I would interpret that exactly how James Mehling does. It might not be the best example of written communication but to me it's not ambiguous, either.

And without knowing what aopa asked, maybe they just got a stupid answer to a stupid question. i.e. if aopa said "Hey EPA why can't we use 100ll in our airplanes forever" then they get a somewhat bureaucratic response that (a) we haven't made any decision about banning lead and (b) we don't tell you what fuel you can use in your airplane, we ban the use of specific chemicals based on public health/environmental concerns.

Richard - your questions:
Other additives that increase octane are for example manganese, iron - components yes some very heavy aromatics make it (like mesitylene in the SWIFT fuel). In summary it has been looked around for 20 + years to find alternatives and the best (cost-wise) is still lead. What is second/third to best is not yet said.
When you speak about the Connies et etc - they were all 115/145 engines and such fuels are impossible to make unleaded at reasonable cost. The truth story is that octane numbers do not tell you the full story. In certain cases "leaded octane numbers" are more than the same "unleaded octane numbers". Actually this is very complicated and really not very well understood even by specialists.
The density (weight)difference of the leaded vs. unleaded fuels are not important as long as they both are AVGAS as per standard D910. The standard controls the resulting fuels to be fairly equal in weight regardless of lead content.
The lead content in AVGAS does not reflect the lubricity of the fuel. However in certain cases lead could contribute to a smother break in if engine parts are not precision manufactured.

Lars--thank you, this is first reasonable explanation I've seen. I understand that part of the unleaded concern is lack of "lubrication" resulting in need for "hardened" valves, valve guides, and cams. Motorcycle engines from the 70's are subject subject to this type of modification if unleaded fuel is used. I assume aircraft engines would need something similar if using totally unleaded fuel?

Richard - in the late 1970:ies AVGAS 100 L and AVGAS 100 LL were introduced. One of the problems with these fuels were hard carbon deposits which damaged the valves. The reason for damaged valves were the valve parts were not made of hardened material. So all aircraft engine manufactures changed their valve parts to meet certain Rockwell hardness data and the problem was solved.
What they DID not know was that they at the same time made the valve system to work on unleaded AVGAS. So in Sweden where we have unleaded AVGAS since 1981 (yes 30 years next year) we put in a requirement that if you use unleaded AVGAS valve system parts must be of 1978 years model or later. Almost 30 years of use of unleaded AVGAS in Sweden proves that the valve systems are OK for no lead.
Regarding lead it does not really lubricate. In the old valve systems it facilitated the heat transfer from the valve head to the seat (and to the cylinder).

Patrick - the current unleaded AVGAS in Sweden is labelled 91/96 UL and was introduced in 1991. It was approved by Lycoming in 1995 in their SI 1070 for a large number of their engines. It was originally intended to cover all engines with a type-certificate of 91/96 but it has several "hidden" capabilities and octane numbers do not tell the full story.
It is a drop in fuel for 100 LL.
You have a lot of information in English on the webb hjelmco.com